Guidelines for written and spoken comment to the Mendocino County Board of Supervisors on The Harris Quarry 2019 Final Environmental Impact Report (EIR)

During the past 15 years of public concern, Keep the Code has won two legal cases (on the original cases and on their appeals) opposing Northern Aggregates wish to build a permanent asphalt plant at Harris Quarry on Ridgewood Grade. The public is now in a limited review period for the third version of the EIR   https://www.mendocinocounty.org/home/showdocument?id=31451. Although both the County’s official notice of the public meeting/input period and Chapter 1 of the 2019 Revised Final Environmental Impact Report attempt to limit comments from the public to “the specific issues under review (Alternatives 4 and 5)”,  we contend that information regarding significant and material new developments in the situation also should be considered.  Accordingly, we strongly urge public comment on all SIGNIFICANT NEW CONSIDERATIONS that have developed since the publication of the previous EIR in 2012.



The deadline for written public comment is end of day on Sunday, December 15th, 2019.

Please attend the following:

Special Public Meeting to Provide Comments to the 2019 Revised Final EIR
9am Monday, December 16, 2019
Board of Supervisors Chambers
501 Low Gap Road, Ukiah

For all documents and staff report regarding the public hearing, see
https://www.mendocinocounty.org/government/planning-building-services/public-notices


SIGNIFICANT NEW CONSIDERATIONS
Keep the Code has identified important SIGNIFICANT NEW CONSIDERATIONS as good directions for public written and oral comment. Please consider choosing one or two talking points from these topics for your letters and public comment to the Mendocino County Planning Department. Short and simple letters are fine- and questions are especially helpful, as they may elicit answers which will likely be very helpful to all in evaluating the project. Please ask interested friends to respond, as well!

1)    A Mobile Asphalt Production Unit would better serve the local and County needs, to be used on location of road building and repair.
a)     This would keep asphalt production near scheduled paving projects, significantly reducing VMT (vehicle miles traveled). VMT advantages are dependent on where the asphalt is needed, and creating the asphalt on site of the road building or repair is significantly more environmentally responsible. A Mobile unit is appropriate for reaching the more remote, under served, areas of the county.
b)    This would scale down the proposal which would reduce ALL environmental impacts, including the VMTs, and eliminate the incentive to truck asphalt out of county. The original proposal, submitted in 2004, was describing trucks every minute or two to serve the Willits Bypass project. This turned out to be a highly inflated projected need since Granite rock [A. R. Wilson] was able to handle the bypass along with their normal business demands, and it only operated making asphalt several days per week. Scaling down the project and siting it appropriately is important in order to meet our more stringent environmental requirements.
c)  Access to the proposed site is difficult and allows for one truck only to enter and exit at a time. All other trucks would have to idle in wait by the highway, increasing pollution.
d)   Additionally, when a mobile asphalt production unit is chosen that is able to “recycle the road”, melting and using recycled asphalt in the new roadwork, significant VMTs are also saved in not having to haul the old asphalt away to be disposed of in another location.


2)    Fire Dangers - hillside fires move fast https://www.cfa.vic.gov.au/plan-prepare/how-fire-behaves, and fire dangers have increased over the past 10 years. Asphalt plants are a well-known fire hazard, and placing an asphalt plant in the middle of fire-prone oak-and-fir woodlands significantly intensifies local fire risk. Access to the proposed site is difficult and allows for one truck only to enter and exit at a time. All other trucks would have to idle in wait by the highway, increasing VMTs.
a)     Black Bart Road - When the 2012 EIR was written, there was an alternate road to travel to escape fire danger or other emergency if Black Bart Road was impassable.  Now, with Muir Mill Road closed, those using Black Bart Road to access their property presently are restricted to only ONE road for ingress and egress. If this road becomes blocked due to fire, residents are trapped, and emergency vehicles and personnel would not be able to provide necessary life-saving assistance. This significantly amplifies the fire danger and personal safety for residents and owners of the 334 properties in this development. Is the County willing to bear the burden of liability for life and safety imposed by approving the siting of an asphalt plant at the beginning of Black Bart Road on U.S. Hwy 101?


3)    Ridgewood Park - Asphalt fumes are dangerous to all local residents, and the elderly are of special concern. An asphalt plant in close proximity to Ridgewood Park assisted living (previously Fiesta Mexicana Restaurant and White Deer Lodge) will have a considerable negative effect on this new population of sensitive elderly. Mendocino County has specified that there is a pressing need for housing, especially for senior residents. Ridgewood Park was designed to help solve this problem. Several permits for the Assisted Living project have already been issued by Mendocino County and completed by the builder, with more scheduled. Approving an asphalt plant to be sited across the road from this 30 unit frail elderly living development is counter to the more pressing needs of the County.  

4)  Projections-Proposed asphalt plant projections have decreased since the 2012 EIR. According to the 2019 EIR, current downward population projections have reduced forecasted local asphalt needs. It is needlessly harmful to build an asphalt plant near vulnerable persons or sensitive environmental locations. Prior EIR approvals were based on projected asphalt needs due to expanding population projections.  We now know those earlier population projections were over-ambitious. The currently operating local asphalt plant, located in an industrial zone on North State Street in Ukiah, meets local asphalt needs while only operating several days per week.


5)    New Climate Goals passed by California - (this section to be further developed) meeting new standards - “state of the art” asphalt production machinery.

 6)    NEW projects and programs at Golden Rule that would be adversely affected by the fumes and pollution from a nearby asphalt plant include:
a)     A new Assisted Living Facility on the Ranch
b)    The New Agrarian Collective
c)     The School of Adaptive Agriculture
d)    Food Hub to make value added products - All of these gardening projects are dedicated to researching and promoting the sustainable production of food with a minimal use of fossil fuels, issues that are vitally important in the face of catastrophic climate change.
e)     New covered Seabiscuit Therapeutic Riding Center Arena
f)     Increase in residents/remodeled rentals at Golden Rule in addition to many other public benefit programs, such as La Vida Charter School and Seabiscuit Heritage Foundation previously addressed in the 2012 EIR public comments.

 7)    Air Quality, Health Impacts and Loss of Property Value - http://www.bredl.org/pdf/BeSafe_Asphalt.pdf
a)     Air Quality shows a dramatic decline from increased particulates…….. American Lung Association State of the Air already rates Mendocino County with an F for particulate pollution, and another asphalt plant will add to that already failing rating. https://www.lung.org/our-initiatives/healthy-air/sota/city-rankings/states/california/mendocino.html
b)    Health Impacts: new or worsened asthma, bronchitis and COPD. Young children and the elderly are at higher risk for these illnesses.
c)     Property value losses vary, depending upon study: between 20% and 56% of value. This translates into a significant reduction in property tax revenue for the county.  



Written Comment to
Mendocino County Board of Supervisors
Supervisors: Carre Brown, John McCowen, John Haschak, Dan Gjerde, Ted Williams
501 Low Gap Road, Room 1010
Ukiah, CA 95482



Copies of your letter may be additionally sent to:
Mendocino County Department of Planning and Building
emailed to pbs@mendocinocounty.org or mailed to:
Mendocino County Department of Planning and Building Services
Attn: Harris Quarry Comments
860 North Bush Street
Ukiah, CA 95482


and

Keep the Code
410 Clara Street
Ukiah, CA 95482



You have a right to clean air, water and a safe environment!
Tell the Supervisors to uphold their Mission Statement!

“The Mendocino County Board of Supervisors’ mission is to create and maintain a responsive and responsible government that enhances the quality of life of the people of Mendocino County. The County’s mission is to deliver services that meet: Public safety, health, social, cultural, education, transportation, economic, and environmental needs of our communities.”